The American Rescue Plan Act of 2021 (ARPA) includes a 100% federal subsidy of COBRA premiums (including the up-to-2% administrative fees) during the period of April 1, 2021, through September 30, 2021. The subsidy applies to group health coverage typically subject to COBRA, except for health flexible spending accounts. This update summarizes the ARPA’s COBRA subsidy provisions and flags key implementation considerations to assist employers and plans with planning as we await critical additional guidance from the U.S. Department of Labor and Internal Revenue Service. Read the full article.